https://www.taxtmi.com/caselaws?id=352586 Transfer pricing under Chapter X is confined to international transactions with the associated enterprise, and ordinary domestic transactions cannot be the basis for adjustment unless they are specified domestic transactions. Where segmental accounts are unavailable, any proportionate adjustment is limited to the international transaction component, reflecting the presumption that non-associated enterprise dealings are at arm's length. The note also states that the reversal of royalty income must be reconsidered alongside the transfer pricing matter in the same reassessment process under section 144C. en-us Thu, 16 Nov 2017 00:00:00 +0530 Sat, 16 Dec 2017 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352586 Transfer pricing under Chapter X is confined to international transactions with the associated enterprise, and ordinary domestic transactions cannot be the basis for adjustment unless they are specified domestic transactions. Where segmental accounts are unavailable, any proportionate adjustment is limited to the international transaction component, reflecting the presumption that non-associated enterprise dealings are at arm's length. The note also states that the reversal of royalty income must be reconsidered alongside the transfer pricing matter in the same reassessment process under section 144C. Case-Laws Income Tax Thu, 16 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352586